Transfer-pricing treatment of ITeS margins excludes pass-through tax recoveries and separate delayed-receivables interest after working-capital adjust...
Capacity-utilisation adjustments under TNMM can neutralise substantiated COVID-related idle costs where underutilisation materially affects profitabil...
TNMM functional comparability requires excluding rice manufacturers from a pure Basmati rice trader's benchmark and recognising operating export recei...
Working-capital adjustment subsumes delayed-receivable effects in TNMM benchmarking of captive software-development services, avoiding separate notion...
Transfer-pricing comparability requires exclusion of financially illogical super-profit comparables and correction of unsupported annual-report and ma...
Charitable character assessment preserves Section 80G approval despite inclusive spiritual teachings and incidental religious expenditure within the s...
Penalty proceedings for cash-loan acceptance require assessment proceedings and recorded Assessing Officer satisfaction; absent these, the proceedings...
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The appellants are required to include pool cancellation charges, pool lifting charges, penalty on dealers and cancellation charges in the assessable value of motor vehicles as per Section 4 of the Central Excise Act, 1944. The CESTAT held that these charges relate to the transaction of sale and are payable by the buyer to the assessee in connection with the sale. All demands are sustained, however, penalties are set aside and cum-duty benefit is ordered to be accorded. Appeal allowed in part.
The appellants are required to include pool cancellation charges, pool lifting charges, penalty on dealers and cancellation charges in the assessable value of motor vehicles as per Section 4 of the Central Excise Act, 1944. The CESTAT held that these charges relate to the transaction of sale and are payable by the buyer to the assessee in connection with the sale. All demands are sustained, however, penalties are set aside and cum-duty benefit is ordered to be accorded. Appeal allowed in part.
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